Authority: Recovery Officer, Securities and Exchange Board of India (SEBI)

Order Date: July 17, 2026

Case Overview

This order disposes of a representation dated June 24, 2026, received from Rich Infra Developers India Limited (the Applicant) challenging the valuation and reserve price fixed for one of its properties scheduled for e-auction. The auction is part of recovery proceedings initiated under Recovery Certificate No. 2823 of 2020 to enforce a SEBI final order dated September 27, 2018. That order had directed the company and its directors to wind up its Collective Investment Schemes and refund money collected from investors, amounting to ₹58,45,00,000. As the defaulter failed to pay, SEBI attached its movable and immovable properties. A Notice of Sale for e-auction of five immovable properties was issued on June 12, 2026. The Applicant specifically challenged the ₹1,80,90,000 reserve price for its 56.40-acre land in Khot Village, Garhshankar Tehsil, Hoshiarpur District, Punjab (Sl. No. 5 in the auction notice). The Applicant contended the price was not commensurate with the land's location and circle rates, relying on an older valuation report from October 2017 that valued a larger parcel (67.62 acres) at ₹17.58 crore. The Applicant requested a fresh valuation, disclosure of SEBI's valuation details, and a deferment of the auction. A personal hearing was scheduled for July 10, 2026, but all attempts to serve the notice (email, post, hand delivery) failed as the company was not contactable at its registered address.

The key issue for consideration was whether the reserve price was reasonable and whether the Applicant's valuation report was reliable. SEBI's valuation was conducted by an IBBI-registered valuer on June 2, 2026. The valuer reported that the 56.40-acre property was classified predominantly as 'Gair Mumkin Pahar' (non-cultivable mountainous land) and partly as 'Agricultural-Burani' in official sale deeds and land revenue records, with no available land conversion documents. The valuation was done on an "As Is Where Is" basis, considering the land's poor physical characteristics: sloping, uneven rocky terrain with no clear physical boundaries or demarcation, and access only via a mud road. This reduced its marketability compared to level agricultural land. The valuer used the Sales Comparison Method, analyzing comparable market transactions and considering factors like land classification, physical characteristics, and local demand and supply. The Guideline Value was calculated using the Government of Punjab's published rates for FY 2025-26. The valuer assessed the Market Value at ₹2,01,00,000 and the Guideline Value at ₹1,72,10,225. The reserve price was set at ₹1,80,90,000 (90% of the Market Value and higher than the Guideline Value).

The Recovery Officer found the Applicant's 2017 valuation report unreliable. It was outdated, valued a different, larger land parcel (a difference of 11.22 acres), lacked transparency in its methodology, and made unsupported claims. It classified the land as 'Agricultural/Mixed use' without providing any conversion orders or documentary evidence to counter the official 'Gair Mumkin Pahar' classification. Its claim that the property abutted the Garhshankar-Nangal Road was contradicted by the IBBI valuer's site inspection. The Applicant's failure to appear for the hearing or cooperate in the recovery process further weakened its case. In contrast, SEBI's valuation was deemed comprehensive, evidence-based, and reflective of current market conditions.

Final Outcome

The Recovery Officer dismissed the Applicant's representation, finding no merit in its objections. The request for a fresh valuation, deferment of the auction, and change in reserve price was denied. The e-auction of all five attached properties, including the Punjab land, will proceed as per the published Notice of Sale dated June 12, 2026, and Corrigendum dated July 03, 2026, using the already fixed reserve prices.

Topics: SEBI Recovery, Property Auction, Valuation Dispute